US v. Jenkins: Jenkins (aka "Big Tim") was confronted by Charleston, South Carolina, police, while carrying a firearm. After he was arrested, officers noticed "a white rock-like substance between his fingers, later identified as .29 gram of cocaine base" while processing him. Jenkins was charged and pleaded guilty to being a felon in possession of a firearm. At sentencing, his offense level was enhanced four levels because he possessed the firearm "in connection with another felony offense" - the possession of cocaine base. Jenkins objected to the enhancement, but the district court applied it and sentenced him to 71 months in prison.
On appeal, the Fourth Circuit affirmed. Jenkins conceded that he committed another felony offense, but argued that his possession of the firearm was not done in connection with it. The court disagreed, concluding that Jenkins's possession of the firearm facilitated, or had the potential to facilitate, his possession of drugs. "[I]t is clear," the court wrote, "that the possession of a firearm can facilitate a simple drug possession offense," as it provides a means for the user to protect his stash and the investment therein. In Jenkins's case, the fact that he took a gun out into the street where a shot had recently been fired showed "there was a heightened need for protection and that the firearm emboldened" him.